Využití konceptu safe harbour pro stanovení převodních cen

Tax administrations worldwide provide taxpayers with favour and offer them the opportunity to set up transfer pricing system according to pre-agreed criteria. When taxpayer´s system complies with, a tax administrator does not dispute the transaction. Any predefined arrangement leading to the recognition of transfer pricing system by the tax administrator can be defined as a safe harbour. It was found out during the review process of current sources, that there is no relevant research available focused on assessing the appropriateness of introducing safe harbour system for both businesses and government. At the same time, even the OECD does not work with data that would conclusively prove the impact of transfer pricing regulation on companies´ behaviour. For this reason, a research was conducted in this area with focus on the potential of safe harbour to affect tax contributions of enterprises. Financial data were rendered from Amadeus database. The impact of safe harbour system was observed on the time series development of taxation of particular cluster. Cluster analysis was selected as the most suitable method for grouping companies.